By May 14, 2025, employers who have 100 or more employees (who have at least 1 employee in California) and/or 100 or more workers hired through labor contractors (with at least 1 of those employees in California) must report certain pay data to the California Civil Rights Department (“CRD”).

Within this report, employers must provide information within these main categories:

• The number of employees (by race, ethnicity, and sex) in job categories along with the median and mean hourly rate.
• The number of employees (by race, ethnicity, and sex) whose annual earnings fall within each of the pay bands used by the United States Bureau of Labor Statistics in the Occupational Employment Statistics survey
• The total number of hours worked during the Reporting Year by each employee, counted in each pay band
• The employer’s North American Industry Classification System (NAICS) code.

Sounds straightforward, or does it? The CRD has provided a general spreadsheet template to help prepare the pay data report along with an exemplar and additional resources. (Click here to view.)

If a covered employer does not submit the required report, the CRD can seek a court order requiring the employer to comply, and/or seek a civil penalty of $100 per employee. If the employer had an initial violation, then the civil penalty is increased to $200 per employee. These penalties can add up.

Avoid the risk of incurring those civil penalties and possible court fees by tackling this task now and submit early! Feel free to reach out to us if you need help preparing and submitting your report.

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